Childrens Online Privacy Protection Act Compliance
We are in compliance with the requirements of COPPA (Childrens Online Privacy Protection Act), we do not collect any information from anyone under 18 years of age. Our website, products and services are all directed to people who are at least 18 years old or older.
California Consumer Privacy Act (COPA) Compliance
Because we value your privacy we have taken the necessary precautions to be in compliance with the California Consumer Privacy Act (COPA).
CCPA - Information We Collect
We have collected (or not collected, as indicated below) the following categories of personal information from our consumers within the last twelve (12) months:
Category A - IDENTIFIERS (Collection Status: YES). Examples of what may be collected that fall into this category: Name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers
Category B - CUSTOMER RECORDS OF PERSONAL INFORMATION CATEGORIES LISTED IN THE CALIFORNIA CUSTOMER RECORDS STATUTE [Cal. Civ. Code § 1798.80(e)]. (Collection Status: YES). Examples of what may be collected that fall into this category: Name, signature, address, telephone number, education, employment, employment history, credit card number, debit card number, or any other methods of payment for our products, or medical information. Some personal information included in this category may overlap with other categories.
Category C - CHARACTERISTICS OF PROTECTED CLASSIFICATIONS UNDER CALIFORNIA OR FEDERAL LAW (Collection Status: YES). Examples of what may be collected that fall into this category: Age, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), veteran or military status. These categories are ONLY collected in very limited circumstances where directly provided by the consumer who has filled out surveys, asked questions or otherwise voluntarily and knowingly provided the information.
Category D - COMMERCIAL INFORMATION (Collection Status: YES). Examples of what may be collected that fall into this category: Records of products or services purchased, obtained, or considered.
Category E - BIOMETRIC INFORMATION (Collection Status: YES). Examples of what may be collected that fall into this category: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Category F - INTERNET OR OTHER ELECTRONIC NETWORK ACTIVITY (Collection Status: YES). Examples of what may be collected that fall into this category: Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
Category G - GEOLOCATION DATA (Collection Status: YES). Examples of what may be collected that fall into this category: Physical location or movements.
Category H - SENSORY DATA (Collection Status: YES). Examples of what may be collected that fall into this category: Audio, electronic, or similar information.
Category I - PROFESSIONAL OR EMPLOYMENT-RELATED INFORMATION (Collection Status: NO). Examples of what may be collected that fall into this category: Current or past job history or performance evaluations.
Category J - NON-PUBLIC EDUCATION INFORMATION PER THE FAMILY EDUCATIONAL RIGHTS AND PRIVACY ACT [20 U.S.C. Section 1232g, 34 C.F.R. Part 99](Collection Status: NO). Examples of what may be collected that fall into this category: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Category K - INFERENCES (Collection Status: NO). Examples of what may be collected that fall into this category: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
We obtain the categories of personal information listed above from the following categories of sources:
- Direct interactions: You may give us your information by filling in forms or by corresponding with us by mail, phone, fax, email or in-person. This includes, but may not be limited to, personal data you provide when you:
a) Purchase our products or request samples;
b) Create a user account on our website;
c) Subscribe to our publications;
d) Request marketing be sent to you;
e) Interact with our website such as through modules, visiting the webstore, or taking quizzes;
f) Interact with social media by visiting our pages, commenting on or liking posts;
g) Enter a competition, promotion or survey; or
h) Provide information in-person at industry events or other venues, or providing information by phone, fax or email.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
a) Technical data from Analytics providers such as Google, and Advertising networks such as Google Adwords, Bing Adcenter, Amazon ads, Criteo sponsored ads, and IPromote display ads; and
b) Data from providers of technical, payment and delivery services such as PayPal.
c) Data from data brokers or aggregators including trade show organizers and other professional association.
d) Data from publicly availably sources such as internet search engines based inside and outside the EU.
CCPA - Use of Personal Information
CCPA - Sharing of Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we require that the recipient both keep that personal information confidential and not use it for any purpose except performing the contract.
We share your personal information with the following categories of third parties:
-Entities owned in whole or in part by our company and/or its shareholders
-Authorized distributors of our products
-Service providers acting as data processors
-Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
-Regulators and other authorities acting as processors or joint controllers based who require reporting of processing activities in certain circumstances.
CCPA - Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Category A - IDENTIFIERS
Category B - CUSTOMER RECORDS OF PERSONAL INFORMATION CATEGORIES LISTED IN THE CALIFORNIA CUSTOMER RECORDS STATUTE [Cal. Civ. Code § 1798.80(e)]
Category D - COMMERCIAL INFORMATION
In the preceding twelve (12) months, we have not disclosed the following categories of personal information for a business purpose:
Category C - CHARACTERISTICS OF PROTECTED CLASSIFICATIONS UNDER CALIFORNIA OR FEDERAL LAW
Category E - BIOMETRIC INFORMATION
Category F - INTERNET OR OTHER ELECTRONIC NETWORK ACTIVITY
Category G - GEOLOCATION DATA
Category H - SENSORY DATA
Category I - PROFESSIONAL OR EMPLOYMENT-RELATED INFORMATION
Category J - NON-PUBLIC EDUCATION INFORMATION PER THE FAMILY EDUCATIONAL RIGHTS AND PRIVACY ACT [20 U.S.C. Section 1232g, 34 C.F.R. Part 99]
Category K - INFERENCES
CCPA - Sales of Personal Information
CCPA - Your Rights and Choices / Access to Specific Information and Data Portability Rights
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
-The categories of personal information we collected about you
-The categories of sources for the personal information we collected about you
-Our business or commercial purpose for collecting that personal information
-The categories of third parties with whom we share that personal information
-The specific pieces of personal information we collected about you (also called a data portability request).
-If we disclosed your personal information for a business purpose, the personal information categories that each category of recipient obtained.
CCPA - Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
-Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
-Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
-Debug products to identify and repair errors that impair existing intended functionality.
-Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
-Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
-Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
-Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
-Comply with a legal obligation.
-Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
CCPA - Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by:
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
-Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
-Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
CCPA - Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
CCPA - Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
-Deny you goods or services.
-Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
-Provide you a different level or quality of goods or services.
-Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.